PRIVACY POLICY
Created: September 2018
Detroit Regional Chamber Foundation (“Chamber”) is committed to protecting the privacy of individuals and has created this Privacy Policy in compliance with the law and in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and dissemination practices for our Let’s Detroit program and Chamber’s related websites, Letsdetroit.com, letsdetroit.org, textadetroiter.com, textadetroiter.org (the “Sites”). The terms “we” and “our” refer to Chamber and all associated companies and subsidiaries.
GENERAL DISCLOSURE
This Site is hosted in the United States and intended for U.S. Site visitors. If you are visiting this Site from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States where our data center and servers are located and operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our web site, you understand that your information will be transferred to our facilities in the United States and to third parties with whom we may share your information. If you are visiting this Site outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use this Site. See our Cookies Policy and instructions below.
We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information where we have legitimate interest and in accordance with the law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.
COLLECTION AND USE OF INFORMATION:
We collect personal information from correspondence, faxes, texts, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide you with access to community and regional resources and services, and other lawful purposes. We (and our affiliates and authorized service providers) may collect, store and use:
We also may collect information about your computer or mobile device and your visits to this Site, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information in the administration of this Site, to improve the Site’s usability, to provide better service, to send you newsletters, legal updates, marketing communications, and other information that may be of interest to you. We also use outside services such Google Analytics to gather data about our Site visitors. We may sometimes permit our authorized service providers to have access to aggregate statistics about our clients, Site traffic patterns, usage and related information.
We may share information with trusted third parties who assist us in operating our website and in conducting our business and business relationship with you. Third parties include, as examples, organizations that perform outsourcing and other services for us (such as marketing, payment processors, shipping companies, other Detroit community organizations, and systems development and maintenance organizations).
We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Chamber’s business or assets to such business entity (including due to a sale in connection with a bankruptcy or dissolution). We will require any such purchaser, assignee or other successor business entity to honor the terms of this privacy statement.
We do not allow third parties to collect personal information about your online or mobile activities over time and across different web sites or mobile devices when you use the Site. We also will not sell your personal information.
We rely on the following legal grounds to process your personal information, namely:
COOKIES POLICY
Our Site uses first and third-party cookies for technical, analytical and advertising purposes. “First party cookies” refer to cookies that are set by our Site, and we are the only ones with access to this information. On the other hand, “third party cookies” or requests allow other third parties to have access to the information collected. Not all cookies are necessary to navigate this Site. Cookies used for analytical and advertising purposes, such as site analytics and advertising cookies (non-essential cookies) are not necessary to navigate our Site. You have the choice not to accept or delete them anytime and carry on browsing normally. See below for instructions.
What are cookies and why we use them?
Cookies are files that are downloaded on your computer or mobile device when you visit certain websites. Cookies allow a website, for instance, to identify a user session, recall your preferences (e.g. language), or gather information about your browsing habits. We use essential cookies for our legitimate interest in facilitating your access to and use of the Site, and we ask your consent for using advertising and analytics cookies (non-essential cookies) so we can measure how you interact with the Site content. However, you can withdraw your consent at any time by not allowing cookies.
We may send a cookie which may be stored by your browser on your computer’s hard drive. We use this information for the following purposes:
We also may use “clear gif” pixels in HTML-based emails sent to our users to track which emails are opened by recipients. We may use the information we obtain from the cookie in the administration of this Site, to improve the Site’s usability and for marketing purposes. We may also use that information to recognize your computer or mobile device when you visit our Site, and to personalize our Site for you.
Cookies and information captured through this Site are; stored for a certain retention period; however, you can eliminate these cookies any time before the cookie expiration date.
How to Restrict Cookies
You can adjust the settings in your browser in order to restrict or block cookies that are set by the Services (or any other site on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.
You can control and delete these cookies through your browser settings through the following links:
Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.
Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”,” “Internet Options”,” “Privacy”,” and selecting “Block all cookies”) This will, however, have a negative impact upon the usability of many websites, including this one.
LINKING SITES
The Site contains links to other sites. Chamber is not responsible for the privacy practices or the content of such websites, including any sites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is approved in advance by you. Other linked sites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the sites you may visit by linking from the Site. Please note that this Privacy Policy applies only to our Site, and not to other companies’ or organizations’ websites to which we link.
For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you’ve provided to them or they’ve collected from your use of their services. This information may be stored in Google’s servers in the United States of America according to their privacy practices.
SOCIAL MEDIA
We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the information they may be sharing. If you do not want your networking sites to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. We are not responsible for how these third-party sites may use information collected from or about you.
SECURITY
Chamber employs security measures utilizing industry-standard technology to protect the loss, misuse or alteration of personal information that you disclose through the Site. Personal information is stored in a secured database and always sent via an encrypted Internet channel. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly at privacy@LetsDetroit.com. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect member privacy in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.
DISCLOSURE OF INFORMATION
Chamber may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Chamber, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. Chamber may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.
RESPONSE TO “DO NOT TRACK” SIGNALS
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Chamber does not process or respond to “Do Not Track” signals.
CHILD ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION
The Child Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable information through the site. If you are under the age of 18 and have already provided personally identifiable information through the site, please have your parent or guardian contact us immediately at privacy@LetsDetroit.com. so that we can remove such information from our files.
LIMITATIONS
We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with its obligations under applicable law.
RETENTION OF PERSONAL INFORMATION
We may keep a record of your personal information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies.
ACCESS TO YOUR PERSONAL INFORMATION
Subject to the exceptions provided by the applicable law, we will make available to you any specific personal information about you that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send your request for access to the Privacy Director listed by sending an e-mail to privacy@LetsDetroit.com or call us at 313-596-0371. Please be as specific as possible in your request so that we can meet the applicable time lines.
Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Chamber by contacting us at privacy@LetsDetroit.com.
If you are a resident of the European Economic Area (EEA) the General Data Protection Rule (GDPR) allows Data Subject rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided and the right to lodge a complaint to your Supervisory Authority.
RESPONSE TIMES
We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate privacy commission with respect to this time limit.
COSTS
We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
IDENTIFYING YOU IN CONNECTION WITH REQUESTS
We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information shall be used only for this purpose.
CONTACT
Personal information is generally located at our corporate or divisional offices in the United States. A list of corporations, divisions, subsidiaries and affiliates to which this Privacy Policy applies is available upon request. Please direct all complaints or other inquiries regarding personal information, the Privacy Policy and Cookies Policy to our Privacy Director as follows.
Privacy Director
One Woodward Avenue, Suite 1800, Detroit, MI 48226
privacy@letsdetroitdev.wpengine.com
313-596-0371
CHANGES TO THE PRIVACY POLICY
This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on this Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, you can email privacy@letsdetroitdev.wpengine.com.
The type of cookies we use are:
Cookie name | Type of cookie and Purpose | Source | Retention period |
_ga
|
HTTP Google Analytics – Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | Letsdetroit.com | 2 years
|
_gat | HTTP Google Analyics – Used to throttle request rate | Letsdetroit.com | Session |
_gid | HTTP – Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | Letsdetroit.com | Session |
Collect | Pixel – Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels. | Letsdetroit.com | Session |
wp-api -schema-model | Information provided in the forms on this site plus the date and time the form was submitted, and the users IP address is collected. | Letsdetroit.com | Indefinitely |